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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Kohner Props., Inc. v. Johnson, 553 S.W.3d 280 (2018)

Citation
Kohner Props., Inc. v. Johnson, 553 S.W.3d 280 (2018)
Parent Document
Kohner Props., Inc. v. Johnson, 553 S.W.3d 280 (2018)
Jurisdiction
Missouri (state)
Effective Date
2018-07-03

Other Sections in This Document (45)

Full Text

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The "majority of the courts which permit rent withholding" leave the imposition of an in custodia legis procedure to the sound discretion of the trial court. Restatement (Second) of Prop.: Landlord & Tenant § 11.3, at 377 (Am. Law Inst. 1977); see also Teller v. McCoy , 162 W.Va. 367, 253 S.E.2d 114, 129 (1978) ("[S]everal courts have held that the trial court, upon request, after determining that a fact questions [sic] exists as to a breach of warranty of habitability, may , during the pendency of the action, require the tenant in possession to make future rent payments or part thereof unto the court as they become due.") (emphasis added); Robert S. Schoshinski, American Law of *284Landlord and Tenant § 6:15.10, at 507, 510-11 (Supp. 2018) (collecting numerous cases in which trial courts "without statutory authorization" have the discretion to impose an in custodia legis procedure).